|What's It All About?|
The Radio and Telecommunications Terminal Equipment Directive, known as the R&TTE directive or RTTE for short, is the main route to compliance for Radio and Telecoms equipment that is sold in Europe.
The directive came into force April 2000, replacing the Telecommunications Terminal Directive for Telecoms equipment and mainly National Standards for Radio Transmitters. The good news, and its very good news, is that it's far less onerous than it's predecessor but the bad news, not too bad, is that it gives us choice. Even if you took all the worst choices it will still take less time and cost to get approval now than with the old directive.
This directive is much closer to Self Certification than we have seen before but shifts the emphasis from regulation to surveillance. This enables you to get a product to market much quicker but if it doesn't meet requirements you are much more likely to be found out and forced to withdraw the product. The Essential Requirements for a product cover Health and Safety, EMC, Use of the Radio Spectrum and Specific Requirements for certain classes of equipment. The only equipment types currently that have specific requirements are Marine Radios, Avalanche Beacons and Radios for use on Inland Waterways.
The directive offers four ways of demonstrating requirements, partially at the choice of the manufacturer, and these are given in annexes II, III, IV and V. The main part of demonstrating compliance is compiling a Technical Construction File or TCF (annex II calls this Technical Documentation). The file needs to contain sufficient information to identify the product and show that it is compliant with the essential requirements.
Annex II is aimed at Telecommunications Terminal Equipment and radio terminals where the Harmonised Standards contain test suites. This is the simplest way to demonstrate compliance but carries the highest level of risk. Compliance is demonstrated by the TCF. The manufacturer must also operate a quality control system to ensure that the product will continue to meet the requirements. Unlike it's predecessor, the TTE Directive, there is no formal audit of the manufacturing facility and many companies ignore this requirement. This is foolish, however, because if the product is not consistent it will differ from that described in the TCF and effectively invalidate compliance.
Annex III is aimed at Radio Equipment where the Test Suites needs to be identified by a Notified Body. The requirements of Annex II still apply but the demonstration of compliance given in the TCF is by passing the identified tests. Annex III is usually used in conjunction with Annex IV.
Annex IV has the same requirements as Annex II but the TCF is submitted to a Notified Body and they issue an Opinion (in the strict terms of the annex they only need to issue a negative opinion but most notified bodies will also issue positive opinions where appropriate). This 'Opinion' is the closest thing to an approval under the directive and some Notified Bodies will issue a positive opinion as a certificate that can be included in the TCF.
Annex V, known as Full Quality Assurance, provides an alternative that is attractive to companies who introduce a number of new products each year. Development and manufacturing facilities are audited by the Notified Body then the company can release as many new products as it wants without having to submit documentation to the Notified Body but with their full backing.
If compliance is demonstrated using Annex II the equipment should carry the CE mark (providing, of course, it meets the requirements of any other applicable directives). But if the services of a Notified Body are used (annexes III, IV and V) the CE mark is followed by the number of the Notified Body.
Where Radio Equipment uses frequency bands who's use is not fully harmonised across Europe the Manufacturer or Supplier must notify the Spectrum Usage Authority (Article 6.4) in each member state where the equipment will be sold.